u-5704 scoping comments

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ROY COOPGR
(ioner nor
MICI-IAEL S. RGGAN
Seu ela r
EnVII'Onnle°n(ul LINDA CULPEPPER
QUQII�}� Inleriu� Direelnr
April 2, 2018
MEMORANUUM
'fo: Trace Howell, PE, NCDO'f Divisioi� 3 � �Q
Ilom: Joaime Stee�ilmis, NC Uivision of Water Resources, Wilmington Regional OtTice�J I l�/
Subject Scopuig convnen[s o�� proposed mobility improvements to the College Road (NC 132) and Oleander
Drive (US 76) intersection in New Hanover County, STIP No. U-5704, WBS No. 50114J.FS1.
Reference your cottespondence dated March 28, 2018 in which you requested comments for the referenced project.
Preliminaiy analysis of the project reveals the potential for multiple impacts [o streams and jurisdictional wetlands
in the project area. More specifically, impacts to:
Sh•eam Name River Basin Stream Stream Index 303(d) Listiug
Classification s Number
UC to Bumt Mill Creek Ca e �ear C;Sw 18-74-63-2 Yes
UT to Hewletts Creek White Oak SA;H W 18-87-26 Yes
Further investigations at a higher resoW[ion should be undertaken to verify [he prese�ce of other streams and/or
jurisdictional wetlands in Ihe area. In the even[ that anyjurisdic[ional areas are idenlified, lhe Division of Water
Resources requests thal NCllO"C coiisider the following environmental issues for Ihe proposed project:
Projec[ Specific Comments:
L Burnt Mill Creek, class C;Sw and Hewletts Creek, class SA;HQW have been identified as 303(d) waters of
the State. Bumt Mill Creek is on the 303(d) list for impaired use for aquatic life due to poor
bioclassification and Chlorophyll a. Hewletts Creek is oii [he 303(d) list for impaired use for aquatic life
due to exceeding fecal limits.
2. Hewletts Creek
Review of [he project reveals tha[ the presence of surfaca waters classified as SA; High Quality Waters of
the State in the project study area. "This is one of the highest classifications for water quality.
General Project Comments:
3. The environmental document should provide a detailed and itemized presen[ation of the proposed impacts
to wetlands and streams with corzesponding m�pping. If mitigation is necessary as required by I SA NCAC
2H.0506(h), it is preferable ro presen[ a conceptual (if not finalized) mi[igation plan wilh the environmental
documenta[ion. Appropriate miligation plans will be reyuired prior to issuance of a 401 Waler Quality
Certification.
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4. Env'vonmental impact statement altematives shall consider design criteria that reduce the impacts to streams
and wetlands from storm water runofE These altematives shall include road desig�s Ihat allow for treatment
of the storm water runoff through best management practices as detailed in the most recent version of the
Nor[h Carolina Department of Transportation S[ormwater Best Management Practices Tool box manual,
such as grassed swales, buffer areas, preformed scour holes, retention basins, etc.
5. After the selection of the preferced altemative and prior to an issuance of the 401 Water Quality Certification,
the NCDOT is respectfully reminded that they will need to demonstrate the avoidance and minimization of
impacts to wetlands (and slreams) to the maximum extent practical. In accordance with the Environmental
Management Commission's Rules (ISA NCAC 2H.0506[h]), mitigation will be required for impacts of
greater than 1 acre to weUands. In the event that mitigation is requ'ved, the mitigation plan shall be designed
to replace appropriate lost functions and values. North Cazolina Division of Mitigation Services may be
available for assistance with wetland mitigation.
6. In accordance with the Environmental Management Commission's Rules Q SA NCAC 2H.0506[h]),
mitigation will be requ'ved for impacts of greater than 1501inear feet to any perennial sheam. [n the event
that mitigation is required, the mitigation plan shall be designed to replace appropriate lost functions and
values. The North Carolina Division of Mitigation Services may be available For assistance with stream
mitigation.
7. Future documentation, including the 401 Water Quality Certification Application, shall continue to include an
itemized listing of the proposed wetland and sheam impacts with corresponding mapping.
8. The NCDWR is very concemed with sediment and erosion impacts that could result from this project. The
NCDOT shall address these concems by describing the potential impacts that may occur to the aquatic
endvonments and any mitigating factors [hat would reduce the impacts.
9. An analysis of cumulative and secondary impacts anticipated as a result of this project is required. The type
and detail of analysis shall conform to the NC Division of Water Resource Policy on the assessment of
secondary and cumulative impacts dated April 10, 2004.
10. The NCDOT is respectfully reminded that all impac[s, including but not limited to, bridging, fill, excavation
and clearing, and rip rap to jurisdictional weNands, sheams, and ripazian buffers need to be included in the
final impact calculations. These impacts, in addition to any construction impacts, temporary or otherwise,
also need to be included as part of the 401 Water Quality Certification Application.
i i. Where sheams must be crossed, the NCDWR prefers bridges be used in lieu of culverts. However, we realize
that economic considerations often require the use of culverts. Please be advised that culverts should be
countersunk to allow unimpeded passage by fish and other aquatic organisms. Moreover, in areas where high
quality wetlands or streams are impacted, a bridge may prove preferable. When applicable, the NCDOT
shouldnotinstall_the-bridge-bents-in-the-creek,-to-Utemauimum-extent practicable.
l2. Whenever possible, the NCDWR prefers spanning structures. Spanning strucmres usually do not require
work within the stream or grubbing of the streambanks and do not require stream channel realignment. The
horizontal and vertical clearances provided by bridges shall allow for human and wildlife passage beneath the
structure. Fish passage and navigation by canoeists and boaters shall not be bbcked. Bridge supports (bents)
should not be placed in the stream when possible.
13. Bridge deck drains shall not discharge directly into the stream. Stormwater shall be directed across the bridge
and pre-treated through site-appropriate means (grassed swales, pre-formed scour holes, vegetated buffers, etc.)
before entering the stream. To meet [he requirements of NCDOT's NPDES permit NC50000250, please refer
to the most recent version of the North Carolina Department of Transportation Stormwater Best Management
Practices Toolbox manual for approved measures.
l4. Sediment and erosion conhol measures should not be placed in wetlands or streams.

I5. Borrow/waste areas should avoid wetlands to the maximum extent practicaL Impacts to we[lands in
borrow/was[e areas will need to be presented in the 401 Water Quality Certification and could precipitate
compensatory mitigation.
l6. The 401 Water Quality Certification application will need to specifically address the proposed methods for
stormwater management. More specifically, stormwater shall not be permitted to discharge directly into
streams or surface waters.
l7. Based on the information presented in the document, the magnitude of impacts to wetlands and sVeams may
require a Nationwide (NW) permit application to the Corps of Engineers and correspo�ding 401 Water
Quality Certification. Please be advised that a 401 Water Quality Certification requires satisfactory protection
of water quality to ensure that water quality standazds are met and no wetland or stream uses are lost. Final
permit authorization will require the submittal of a formal application by the NCDOT and written concurrence
from the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and
minimization of wetland and stream impacts to the maximum extent practical, the development of an
acceptable stormwater management plan, and the inclusion of appropriate mitigation plans where appropriate.
18. If concrete is used during construction, a dry work area shall be maintained to prevent d'vect contact between
curing concrete and stream water. Water that inadvertently contacts uncured concrete shall not be discharged
to surFace waters due to the potential for elevated pH and possible aquatic life and fish kills.
19. If temporary access roads or detours aze conshucted, the site shall be graded ro its preconstruction contours
and elevations. Disturbed azeas shall be seeded or mulched ro stabilize the soil and appropriate native woody
species shall be planted. When using temporary structures the azea shall be cleared but not grubbed. Cleazing
the area with chain saws, mowers, bush-hogs, or other mechanized equipment and leaving the stumps and root
mat intact allows the area [o re-vegetate naturally and minimizes soil disturbance.
20. Unless otherwise authorized, placement of culverts and other strucNres in wa[ers and streams shall be placed
below the elevation of the s[reambed by one Foot for all culverts wi[h a diameter greater than 48 inches, and
20 percent of the culvert diameter for culverts having a diameter less than 48 inches, to allow low flow
passage of water and aquatic life. Design and placement of culverts and other structures including temporary
erosion control measures shall not be conducted in a manner that may result in dis-equilibrium of wetlands or
sheambeds or banks, adjacent to or upstream and downstream of the above structures. The applicant is
required to provide evidence that the equilibrium is being maintained if requested in writing by the NCDWR.
[f this condition is unable to be met due to bedrock or other limiting features encountered during construction,
please contact the NCDWR for guidance on how to proceed and to determine whether or not a permit
modification will be required.
21. If multiple pipes or barrels are required, they shall be designed to mimic natural stream cross section as
closely as possible including pipes or banels at flood plain elevation, floodplain benches, and/or sills may be
required where appropriate. Widening the stream channel should be avoided. Stream channel widening at the
inletarantteteRd�fs[ract�e�typica�ly�ecreases watee vet�city causirigs�dimentziepositiaer[hatT�qaires
increased maintenance and disrupts aquatic life passage.
22. If foundation test borings are necessaty; it shall be noted in the document. Geotechnical work is approved
under General 401 Cer[ification Number 41323/Nationwide Permit No. 6 for Survey Activities.
23. Sediment and erosion control measures sufficient to protect water resources must be implemented and
maintained in accordance with [he most recent version of North Carolina Sediment and Erosion Conhol
Planning and Design Manual and the most recent version of NCS000250.
24. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP measures
&om [he most current version of the NCDOT Construction and Maintenance Activities manual such as
sandbags, rock berms, cofferdams and other diversion structwes shall be used to prevent excavation in
flowing water.

25. While the use of National Wetland Inventory (N W I) maps, NC Coastal Region Evaluation of Wetland
Significance (NGCREWS) maps and soil survey maps are useful tools, the'v inherent inaccuracies require
that qualified personnel perform onsite wetland delineations prior to permit approval.
26. Heary equipment should be operated &om the bank rather than in skeam channels in order to minimize
sedimenta[ion and reduce the likelihood of introducing other pollutants into streams. This equipment shall be
inspected daily and maintained to prevent contamination of surface waters from leaking fuels, lubricants,
hydraulic fluids, or other toxic materials.
27. Riprap shall not be placed in the active thalweg channel or placed in the sheambed in a manner that precludes
aquatic life passage. Bioengineering boulders or structures should be properly designed, sized and installed.
28. Riparian vegetation (native trees and shrubs) shall be preserved to the maximum extent possible. Riparian
vegetation must be reestablished within the conshuction limits of the project by the end of the growing
season following completion of construction.
Thank you for requesting our input at this time. The NCDOT is reminded that issuance of a 401 Water Quality
Certification requires that appropriate measures be ins[ituted to ensure that water quality standards are met and
designated uses are not degraded or lost. If you have any questions or requ've additional information, please contact
Joa�me Steenhuis at [phone] [e-mail].
Electronic copy only dishibution:
Paul Koch, PE, Stantec
Brad Shaver, US Army Corps of Engineers, Wilmington Field Office
Mason Hemdon, DEO NC DOT Division 3
Cathy Brittingham, NC Division of Coastal Management
Stephen Lane, NC Division of Coastal Management
Kristi Lynn Carpenter, NCDWR
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